An analysis paper by the NAACP Legal Defense and Educational
Fund, Inc.

Serious Problems With The Proposed Voluntary
National Tests of Reading and Mathematics

The Department of Education's effort to develop and administer Voluntary
National Tests in Reading and Mathematics for 4th and 8th grade students
creates cause for real concern about harm to children through misuse of
the tests if they are developed and implemented under the current proposal.

The tests will be used for high stakes decisions about students' futures:
Testing experts agreed at a recent meeting of the Board on Testing and Assessment
of the National Research Council that the tests inevitably will be used
for many purposes including retention in grade, ability grouping, tracking,
graduation, and possibly teacher assessment. While the Department has said
that the tests will be for information purposes for parents, students and
teachers, the testing experts agree that they, in fact, will be used to
make high stakes decisions for school children and possibly for teachers.

The Department has no plans to validate the tests: The consensus
of professional educators and social scientists (as reflected in the "Standards
for Educational and Psychological Testing" adopted jointly by the American
Educational Research Association, the American Psychological Association,
and the National Council for Measurement in Education) is that every separate
use of a test instrument must be "validated" -- that is, examined
scientifically to insure that the test is an appropriate and reliable measure
for the specific purpose for which it is being used. Despite the knowledge
that tests with the imprimatur of the Federal Government will be used to
make critical decisions about educational opportunities for children, the
Department has no plan to validate them for these purposes. This means
that we are virtually certain that the tests will be misused.

The NAACP Legal Defense Fund (LDF) has just filed, July 29, 1997, a
case in North Carolina challenging the misuse of a standardized test to
retain children in grade. The widespread misuse of tests has particularly
harsh and disproportionate adverse consequences for poor and minority children.
These misuses result in the gross overrepresentation of poor and minority
children in low-end classes and low curriculum tracks which ultimately limit
opportunity and deny the life-long benefits of a quality education.

The Department has no plan to establish any mechanism to enforce
traditional testing guidelines prohibiting test misuse: When asked about
an enforcement mechanism at the Department to police and enforce guidelines
against test misuse, the response given by Department officials is only
that no decision has been made on the issue of enforcement.

The reading test for 4th graders is to be offered in English only:
As the Nation experiences an increasingly diverse population and children
who speak and read in many languages other than English, it is both discriminatory
and unwise to treat large segments of the population as non-persons by failing
to recognize reading proficiency of young children in languages other than
English. The negative stigmatizing effects of "English only"
national tests are harmful and inappropriate for a Nation of people of many
backgrounds.

The tests are not for diagnostic purposes: The Department has
stated that the tests are not for diagnostic purposes. Therefore, the tests
are not designed or intended as an aid to teachers who are assessing a student's
skill level or determining an appropriate curriculum to improve the reading
or math skills of a particular student.

Parents, students and teachers will not be given any information
that will help them determine and/or respond to the factors contributing
to a student's test score: While the stated intent in developing these
national tests is to empower parents with information, the failure to give
"opportunity to learn" information such as the level of education
of the teacher, teacher certification in field, school funding levels, availability
of books and other supplies, and pupil/teacher classroom ratios means that
the test scores will be of little value for parental action to improve the
quality of education offered to their children.

The serious problems that the LDF and others have raised about the proposed
Voluntary National Tests have not been answered. LDF is opposed to the
Department's testing initiative as currently designed.

(The NAACP Legal Defense & Education Fund, Inc. is
not part of the National Association for the Advancement of Colored People
(NAACP) although LDF was founded by the NAACP and shares a commitment to
equal rights. LDF has a separate Board, programs, staff, office and budget.)